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PRIVACY POLICY

 1. Euromonitor
 2. Privacy Policy


EUROMONITOR INTERNATIONAL LTD

UPDATED: NOVEMBER 2020

Euromonitor International Ltd (we, us, our, as applicable) takes your privacy
seriously. This privacy policy describes how Euromonitor International Ltd
collects, processes and stores your personal data when you use our services,
websites, social media pages, applications, products or software, the purposes
for which it is used and with whom it is shared.

Our registered office address is 60-61 Britton Street, London, EC1M 5UX. We are
registered with the Information Commissioner’s Office as a data controller
(registration number ZA685624).

For current and past employees our Workforce Privacy Policy relating to how we
collect, process and store personal data of our staff can be found here.

This policy was last updated on the date that appears at the top of this page.

 


1. WHO WE ARE

For the purposes of data protection law, Euromonitor International Ltd is the
controller of the personal data it collects from you.  This means that it
decides why and how your personal data is processed and is responsible for that
processing.

Our Data Protection Team is responsible for responding to queries relating to
this privacy policy. If you have any questions about this privacy policy,
including any requests related to your personal data, please contact our Data
Protection Team using this email address: DataProtection@euromonitor.com.

Please see the end of this policy for our legal and contact information.






2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Euromonitor International Ltd collects personal data from you if you (or an
organisation for whom you work) purchase or use our services, request
information, register for an event, sign up to an e-alert service, request
customer support or correspond with us.

 

We collect and process the following personal data about you:

 * Identity information, such as your first name, maiden name, last name,
   username or similar identifier, marital status, title, date of birth and
   gender.
 * Contact information, such as billing address, delivery address, email address
   and telephone numbers.
 * Financial information, such as payment related information.
 * Transaction information, such as details about payments to and from you and
   other details of products and services you have purchased from us.
 * Technical information, such as internet protocol (IP) address, your login
   data, browser type and version, location, operating system and platform and
   device and cookie IDs on the devices you use to access this website and our
   other web-based products. Please see our Cookie Policy for further details.
 * Profile information, such as your username and password, purchases or orders
   made by you or on behalf of an organisation, your interests, preferences,
   feedback and survey responses.
 * Usage information, such as information about how you use our website,
   products and services. Our technologies automatically collect and log certain
   information to help us administer, protect, and improve our services, analyse
   usage and improve user experience.

 

Marketing and communications information, such as your preferences in receiving
marketing from us and, where applicable, third parties and your communication
preferences.

Other information relating to you which you may provide to us, for example in
the correspondence that you send to us.

We may hold information about you that has not come directly from yourself. It
may, for example, come from your employer, other organisations, such as
educational institutions, to which you belong, if they use our services and
products. We also collect personal data from third parties such as our partners
and associates, and publicly available websites, to help us maintain data
accuracy and provide and enhance our services and products. Please see
further How do we collect your personal data?

We share personal data with others only as described in this Statement, or when
we believe that the law otherwise permits or requires it. Please see
further With whom do we share your personal data?

Euromonitor International Ltd may request personal data as part of the
recruitment and employment process or as anonymised input into our services and
products.  This includes and is not limited to anonymised consumer surveys
conducted via online panel as well as regular surveys sent to our employees and
clients.






3. HOW DO WE COLLECT YOUR PERSONAL DATA?

We use different methods to collect personal data from and about you as follows:

 

3.1. Direct contact with you during the course of business. You may give us your
contact details, payment details for invoice purposes, by placing an order
online, at events or by corresponding with us by post, phone, email or in other
ways (all of which are provided by you on voluntary basis). This includes
personal data you provide when you:

 * subscribe to our products or publications
 * create an account on our website
 * request marketing information to be sent to you
 * respond to our surveys
 * provide us with some feedback on our products or services
 * provide us with your contact details for us to assist you with using our
   products
 * interact with us at events and meetings

If you do not provide this information, we will not be able to interact or
communicate with you to provide our services in the ways mentioned above.

 

3.2. Automated interactions with our website where we may automatically collect
technical data about your equipment, browsing actions and patterns. We collect
this personal data by using cookies, server logs and other similar technologies.
Please see our Cookies Policy for further details including details regarding
the consequences if we are not able to use these technologies.

 

3.3. Using third party or publicly available sources, where we may receive
personal data about you from:

 * Your employer or organisation for whom you work where that organisation is a
   client, supplier, commercial partner or other company with whom we have a
   business or contractual relationship. The terms of our contract with your
   employer or organisation may require us to process your personal data in
   order to comply with our obligations under that contract or to exercise our
   rights under it.
 * Analytics providers such as Google Inc. based outside the EU
 * Survey and marketing companies based inside and outside the EU
 * Contact, financial and transaction data from providers of technical, payment
   and delivery services who host our data inside and outside of the EU.
 * Identity and contact data from publicly availably sources such as Companies
   House.

 


4. HOW DOES EUROMONITOR INTERNATIONAL USE PERSONAL DATA?

We process your personal data for the purposes listed below.



Passport

 * Account setup and administration: We use your personal data such as your
   name, email and domain address, phone number, and information to set up and
   administer your account, provide technical and customer support and training,
   verify your identity, and send important account, subscription, and Service
   information.
 * Chat rooms, messaging, community and event forums:  When you use our chat
   rooms, messaging, community and event forums we may collect details of visits
   made including, but not limited to the number of visits, logs, IP address
   which are only used for in-house analysis to improve the user experience and
   service performance. Personal data and other user information collected by
   our chat rooms and forums are used in order to complete your registration and
   at the same time to ensure access to our Services and products. Any personal
   data provided in connection with the correspondence between you and
   Euromonitor International Ltd, for example to report a problem with our
   products or raise a query or comment shall be used strictly to reply to you.
 * Hosted services:  Passport provides data and document storage as an integral
   part of the product or solution offering. Documents and data stored by our
   customers may contain personal data or information classified as
   "confidential" by the organisation you work for or are affiliated with. Any
   information stored by or on behalf of our customers is controlled and managed
   by and only made accessible to those customers or others our customers may
   authorise from time to time. Our access to this information is limited to
   Euromonitor International Ltd personnel with a critical business reason.
   
   

VIA

 * Account setup and administration: We use your personal data such as your
   name, email and domain address, phone number, and information to set up and
   administer your account, provide technical and customer support and training,
   verify your identity, and send important account, subscription, and Service
   information.
 * Chat rooms, messaging, community and event forums:  When you use our chat
   rooms, messaging, community and event forums we may collect details of visits
   made including, but not limited to the number of visits, logs, IP address
   which are only used for in-house analysis to improve the user experience and
   service performance. Personal data and other user information collected by
   our chat rooms and forums are used in order to complete your registration and
   at the same time to ensure access to our Services and products. Any personal
   data provided in connection with the correspondence between you and
   Euromonitor International Ltd, for example to report a problem with our
   products or raise a query or comment shall be used strictly to reply to you.
 * Hosted services:  Via provides data and document storage as an integral part
   of the product or solution offering. Documents and data stored by our
   customers may contain personal data or information classified as
   "confidential" by the organisation you work for or are affiliated with. Any
   information stored by or on behalf of our customers is controlled and managed
   by and only made accessible to those customers or others our customers may
   authorise from time to time. Our access to this information is limited to
   Euromonitor International Ltd personnel with a critical business reason.
   
   

Consulting

 * Personalisation: We use personal data to deliver and suggest tailored content
   to personalise your experience with our services and websites.
 * We use personal data such as names, emails and domain addresses, phone
   numbers, and information to set up and carry out research, however the exact
   personal data processed will depend on the services to be provided. Where we
   engage with clients for consulting/research services, we may collect and
   process personal data in order to satisfy our obligations under the statement
   of work.
 * We do not collect special category personal data for research projects. We
   request that clients only provide the personal data that is required for us
   to fulfil our obligation.
   
   

Where data is collected for consulting/research services, it is used for several
purposes, such as;

 * Providing services to clients – data is processed in order to provide the
   service detailed in statement of work;
 * Client management – when communicating with and assessing the needs of
   clients, personal data may be processed in order to ensure that their needs
   are met. This may include assessing whether the right collection of services
   is being provided to our clients;
 * Administration – in order to manage and administer our services, we may
   collect and process personal data. This may include (but is not limited to)
   maintaining internal business records, managing client relationships, hosting
   events and administering client facing applications.
   
   

Surveys

 * We sometimes run surveys to help us with our research. You control how much
   information you share with us.
 * We will only retain your personal data for as long as we need to in order to
   fulfil the uses we describe in this notice (or until you exercise your right
   to erasure, which is explained in the section about your rights).
   
   

Marketing

We use your personal data to deliver marketing and event communications to you
across various platforms, such as email, telephone, text messaging, direct mail,
and online. If we send you a marketing email, it will include instructions on
how to opt out of receiving these emails in the future. We also maintain email
preference for our services for you to manage your information and marketing
preferences. Please remember that even if you opt out of receiving marketing
emails, we may still send you important service information related to your
accounts and subscriptions.

We process your personal data for direct marketing purposes on the basis that it
is necessary for us to pursue our legitimate interests as a business (see above
in this section for further details).  From time to time we may tailor and
personalise marketing communications that we send to you, for example, by
notifying you of products, services, offers or promotions that apply to your
interests, location, industry sector, employer or job role.

We process your personal data for the below purposes on the basis that the
processing is necessary for us to pursue our legitimate interests as a business.
When we rely on legitimate interests, we conduct legitimate interest assessments
to demonstrate accountability in considering and protecting people’s rights and
interests.

If you do not wish to receive marketing communications from us, you can opt-out
at any time by using the unsubscribe link inside the email (to unsubscribe from
marketing emails), by sending an email to emailresponses@euromonitor.com or by
using our Subscription Centre to change your profile settings.



HR / Recruitment

We collect personal data for our staff as part of the administration, management
and promotion of our business activities.

Please see our Workforce Privacy Policy for further details.

Where an individual is applying to work for us, personal data is collected
through the application process. Data collected on applicants via the website
will be used for the purposes detailed below.

 * Employment – we process an applicant’s personal data in order to assess their
   potential employment at Euromonitor; and
 * Administration and management – we may also use this personal data in order
   to make informed management decisions and for administration purposes.
   
   

Administrative and Technical Aspects of Our Business

General administration: We use your personal data for the following legal and
administrative purposes:

 * to administer our websites and our social media pages and for internal
   operations, including troubleshooting, testing and statistical reporting
   purposes;
 * to enable us to make payments to contractors and freelancers who provide
   services to us;
 * for the prevention of fraud and other criminal activities;
 * to meet our internal and external audit requirements;
 * for network and information security purposes for us to take steps to protect
   your information against loss or damage, theft or unauthorised access;
 * to comply with a request from you in connection with the exercise of your
   rights (for example where you have asked us not to contact you for marketing
   purposes, we will keep a record of this on our suppression lists in order to
   be able to comply with your request);
 * for the purposes of a corporate restructure or reorganisation or sale of our
   business or assets;
 * for efficiency, accuracy or other improvements of our databases and systems
   e.g. by combining systems or consolidating records we or our group companies
   hold about you;
 * to enforce or protect our privacy, safety, property or contractual and other
   legal rights or to bring or defend legal proceedings;  
 * to respond to non-mandatory requests from courts, law enforcement agencies,
   regulatory agencies, and other public and government authorities, which may
   include such authorities outside your country of residence; and
 * for general administration including managing your queries, complaints, or
   claims, to send service messages and to provide you with important
   information about our business.
   
   

We process your personal data to comply with our legal obligations including:

 * to verify the accuracy of information we hold about you;
 * to keep a record relating to the rights you exercise in connection with our
   processing of your personal data;
 * to respond to mandatory requests from courts, law enforcement agencies,
   regulatory agencies, and other public and government authorities, which may
   include such authorities outside your country of residence; and
 * to respond to and resolve your complaints relating to the services we
   provide.
   
   
   


5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

Euromonitor International Ltd only shares or discloses personal data when
necessary to provide its services or conduct our business operations as
described below. When we share personal data, we do so in accordance with our
documented data privacy and security requirements. We may occasionally share
non-personal, anonymised, and statistical data with third parties, including
survey findings from our online consumer panels, employees and clients. Below
are the parties with whom we may share your personal data and the reasons that
we share that information.

 

Our Suppliers, Service Providers and Other Recipients

We may share your information with our third-party service providers, agents,
subcontractors and other organisations (as listed below) for the purposes of
providing services to us or directly to you on our behalf.   

 * Recipient / relationship to us 
 * Industry sector (& sub-sector)   
 * Accountancy services   
 * Professional services (accountancy)   
 * Advertising/digital agencies   
 * Marketing (advertising and digital)   
 * Banks, payment processors and financial services providers   
 * Financial (banking)   
 * Cloud storage providers   
 * IT (cloud services)   
 * Direct marketing service providers   
 * Marketing (direct marketing)   
 * Financial auditing services   
 * Audit (financial)   
 * Government tax administration offices   
 * Government (tax)   
 * IT support service providers   
 * IT (support and maintenance)   
 * Legal advisers 
 * Professional services (legal services)   
 * On-site security access control services   
 * Security (on-site)

 

The recipients mentioned above are located in the European Economic Area and the
USA. Where we transfer personal data to recipients in the USA, we ensure that
EU/UK Standard Contractual Clauses are signed between the parties to protect
personal data transferred.

When we use third party service providers, we only disclose to them any personal
data that is necessary for them to provide their service and we have a contract
in place that requires them to keep your information secure and not to use it
other than in accordance with our specific instructions.When we share your
personal data with third parties that are controllers of that information, they
may disclose or transfer it to other organisations in accordance with their data
protection policies. We only transfer personal data to any parties who have been
subject to rigorous due diligence and with whom there is a clear data sharing
contract in place between us and the third parties. This does not affect any of
your data subject rights as detailed below. Where you ask us to rectify, erase
or restrict the processing of your information, we ensure that this request is
passed on to any such third parties with whom we have shared your personal data.



Other Ways We May Share Your Personal Data

 * Our content and event partners: We occasionally partner with other
   organisations who provide content, or host events, which may be held anywhere
   in the world. As part of these arrangements, you may be a client (or work for
   a client) of both Euromonitor International Ltd and our partners, and we and
   our partners may collect and share information about you. We will handle
   personal data in accordance with this policy.
 * Third parties for re-organisation: We may disclose your personal data to any
   third party who is restructuring, selling, buying or acquiring some or all of
   our business or assets (or contemplating doing so) or in the event of a
   merger, bankruptcy, dissolution, re-organisation or similar event to with any
   parties involved in those processes or transactions.
 * Third parties for legal reasons: We will share personal data only when we
   believe it is required, such as:
   
   
   * If we are under a duty to disclose or share your information in order to
     comply with any legal or regulatory obligation or police, court or
     government request, which may include such authorities outside your country
     of residence;
   * To comply with legal obligations and respond to requests from government
     agencies, including law enforcement and other public authorities; and
   * To protect our rights, users, systems, and services.






6. WHERE AND HOW DOES EUROMONITOR INTERNATIONAL LTD TRANSFER YOUR PERSONAL DATA?

Euromonitor International Ltd is a global organisation, and your personal data
may be stored and processed outside of your home country. We take steps to
ensure that the information we collect is processed according to this Privacy
Policy and the requirements of applicable law wherever the data is located.

When we transfer personal data from the European Economic Area to other
countries (‘third countries) in which applicable laws do not offer the same
level of data privacy protection as in your home country, we take measures to
provide an appropriate level of data privacy protection. In other words, your
rights and protections remain with your data. For example, we use Standard
Contractual Clauses, multiparty data transfer agreements and other measures
designed to ensure that recipients of your personal data in third countries
protect it. If you would like to know more about our data transfer practices or
to obtain a copy of the safeguards we use, please contact our Data Protection
Team by email at DataProtection@euromonitor.com.

Euromonitor International Ltd has networks, databases, servers, systems, and
support located throughout our offices globally, please see our office
locations page for a list of Euromonitor International Ltd locations. We
collaborate with third parties such as cloud hosting services, located around
the world to serve the needs of our business, workforce, and customers. We take
appropriate steps to ensure that personal data is processed, secured, and
transferred according to applicable law. As a global organisation, we may need
to transfer your personal data within Euromonitor International Ltd or to third
party cloud hosting providers, outside of your home country. Please see
further Section 6 - With whom do we share your personal data.

Our Data Protection and Information Security team conduct rigorous due diligence
on third party providers to ensure that security of any personal data is
paramount.

 

 


7. SECURING YOUR PERSONAL DATA

Euromonitor International Ltd uses appropriate technologies, policies, processes
and procedures to protect personal data. Our information security policies and
procedures are closely aligned with widely accepted international standards and
are reviewed and updated regularly to reflect changes in legislation and in
business needs.

Examples of the technologies, policies, processes and procedures we maintain
are:

 * We have measures in place to protect against accidental loss and unauthorised
   access, use, destruction, or disclosure of data;
 * We have a framework of policies and procedures which ensure we regularly
   review the appropriateness of the measures we have in place to keep the data
   we hold secure.
 * We have a Business Continuity and Disaster Recovery strategy that is designed
   to safeguard the continuity of our service to our clients and to protect our
   people and assets;
 * We place appropriate restrictions on access to personal data;
 * We implement appropriate measures and controls, including monitoring and
   physical measures, to store and transfer data securely;
 * We regularly conduct security awareness and data protection training for
   employees and contractors annually and as necessary;
 * We take steps to ensure that our employees and contractors operate in
   accordance with our information security policies and procedures and any
   applicable contractual conditions;
 * We require, using contracts and security reviews, our third-party vendors,
   service providers and their sub-contractors to protect any personal data with
   which they are entrusted in accordance with our security policies and
   procedures.

 

 


8. HOW LONG DO WE KEEP YOUR DATA?

We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. We have an internal Data Retention
Policy which mandates the retention of personal data only for as long as is
necessary to serve the purpose for which it was collected.

The length of time we retain your personal data is determined by several factors
including the purpose for which we use that information and our obligations
under other laws.  We determine the period of retention of your personal data
based on the following criteria:

 * Retention in case of queries. We will retain your personal data in case of
   queries from you, including on behalf of an organisation for whom you work.
 * Retention in case of claims. We will retain certain of your personal data for
   the period in which you or a third party might bring claims against us.
 * Retention in accordance with legal and regulatory requirements. We will
   carefully consider whether we need to retain your personal data after the
   period described above in case of a legal or regulatory requirement.

 

The exceptions to the above are where:

 * you exercise your right to require us to retain your personal data for a
   period longer than our stated retention period (see further Restriction of
   processing below);
 * you exercise your right to have the information erased (where it applies) and
   we do not need to hold it in connection with any of the reasons permitted or
   required under the law (see further Request deletion below);
 * we bring or defend a legal claim or other proceedings during the period we
   retain your personal data, in which case we will retain your personal data
   until those proceedings have concluded and no further appeals are possible;
   or
 * in limited cases, existing or future law or a court or regulator requires us
   to keep your personal data for a longer or shorter period.

 

When we no longer need your personal data, we securely delete or destroy it.

 

 


9. YOUR RIGHTS

The European Union's General Data Protection Regulation (GDPR), The UK’s Data
Protection Act 2018 and other applicable data protection laws provide you with
rights over your personal data.

Euromonitor International Ltd respects your right to access and control your
information, and we will respond to requests for information and, where
applicable, will correct, amend, or delete your personal data. Please remember,
that on occasions your personal data may have been shared with you by your
employer or by other organisations, such as educational institutions, to which
you belong, if they use our services and products.

If you wish to exercise any of your rights listed below, please contact our Data
Protection team by email at DataProtection@euromonitor.com. We will respond to
you within 1 month after we have received this information or, where no such
information is required, after we have received full details of your request.

 * Information regarding processing: You have the right to be informed about
   why, how and by whom your personal data is processed (which is what this
   policy sets out to do).
 * Access to personal data: If you request access to a copy the personal data we
   hold about you, we will gladly comply, subject to any relevant legal
   requirements and exemptions, including completing our identity verification
   procedures. Before providing data to you, we will ask for proof of identity
   and enough information about your interaction with us so that we can locate
   any relevant data.
 * Request correction: You have the right to correct or amend your personal data
   if it is inaccurate or requires updating.
 * Request deletion:  You have the right to request deletion of your personal
   data; however, this is not always possible due to legal requirements and
   other obligations and factors. Remember that you can update your account
   information by using the "Contact Us" option within the relevant service.
 * Object to processing:  If you object to the processing of your personal data,
   or if you have provided your consent to processing and you later choose to
   withdraw it, we will respect your choice in accordance with our legal
   obligations. In relation to Marketing preferences: You can opt out of email
   marketing; you can use the unsubscribe link found in the email communication
   you receive from us or visit the applicable email preference centre. For
   other marketing preferences, you can use the "Contact Us" option within the
   relevant Service. Please see further Marketing Please see also information
   related to controlling cookies, which is located in our Cookies Policy. 
 * Restriction of processing:  You can ask us to suspend the processing of your
   personal data if you want us to establish the accuracy of the information;
   where our use of the information is unlawful but you do not want us to erase
   it; where you need us to hold the information even if we no longer require it
   as you need it to establish, exercise or defend legal claims; and you have
   objected to our use of your data but we need to verify whether we have
   overriding legitimate grounds to use it.
 * Request personal data transfer ("data portability"):  We will provide to you,
   or a third party you have chosen, your personal data in a structured,
   commonly used, machine-readable format. Note that this right only applies to
   automated information which you initially provided consent for us to use or
   where we used the information to perform a contract with you.
 * Automated decision making: We will only make a decision that may
   significantly affect you (and for which we use only automated processing) in
   the ways the law permits and that are described in this privacy policy. 
   Where we are permitted to make such a decision in these ways, you may contest
   that decision by emailing DataProtection@euromonitor.com.
 * Withdraw consent at any time: You have the right to withdraw your personal
   data where we are relying on consent to process it. However, this will not
   affect the lawfulness of any processing carried out before you withdraw your
   consent. If you withdraw your consent, we may not be able to provide certain
   products or services to you. We will advise you if this is the case at the
   time you withdraw your consent.
   
   

Making a complaint: If you are not satisfied with how Euromonitor International
Ltd manages your personal data, you have the right to make a complaint to a data
protection regulator in Europe, in particular in a country you work or live or
where your legal rights have been infringed.  The contact details for the
Information Commissioner’s Office (ICO), the data protection regulator in the
UK, are available on the ICO website. A full list of National personal data
Protection Authorities can be found
here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

Where your personal data has or is being used in a way that you believe does not
comply with data, however, we encourage you to contact us before making any
complaint and we will seek to resolve any issues or concerns you may have.

 

 


10. INTERNATIONAL TRANSFERS

Euromonitor International Ltd is committed to compliance with the UK GDPR & Data
Protection Act 2018, the EU GDPR and relevant data protection requirements as
required by law in countries in which our offices are based.

When we are involved in transfers of personal data to countries that are not
deemed adequate by the UK or EU Data Protection Authorities, we use appropriate
safeguards for those transfers, mostly the use of standard contractual data
protection clauses adopted by a supervisory authority and approved by the
Commission, to ensure that safeguards are met.

We also comply with industry standard Data Protection Obligations, such as the
GEANT Data Protection Code of Conduct and ESOMAR Data Protection Checklist.

To contact us about this, please write to the data protection team at our
registered office address below or email us at dataprotection@euromonitor.com.

 

 


11. LINKS TO THIRD PARTY WEBSITES

Our websites and social media pages contain links to third party websites that
are not subject to this Privacy Policy. Euromonitor International Ltd strongly
recommends that you read the privacy policy of any such websites that you visit,
before using the site or providing any personal data.

 

 


12. POLICY CHANGES

Euromonitor International Ltd may change this Privacy Policy at any time by
sending you an e-mail with the modified Privacy Policy or by posting a copy of
them on the website. Any changes will take effect seven (7) days after the date
of our e-mail or the date on which we post the modified Privacy Policy on our
website, whichever is the earlier.

 

 


13. CONTACT AND LEGAL INFORMATION

To contact us for any reason, including to exercise any of your rights in
relation to your personal data, please write to the Data Protection Team at our
registered office address below or email us at DataProtection@euromonitor.com.

You can also contact us by:

 * Telephone (Switchboard): + 44 (0)20 7251 8024
 * Fax: +44 (0)20 7608 3149
 * E-mail: info@euromonitor.com

 

Euromonitor International Limited is a company incorporated in England & Wales
under company registration number 01040587 and has its registered office address
at 60-61 Britton Street, London, EC1M 5UX.

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